Distributed Authority and Examinable Records
Federal AI governance now runs on evidence. Agencies remain accountable for AI that contractors build and operate on their behalf, and contractors face requirements to prove, not assert, that their AI is governed. FERZ provides the authorization boundary and the evidence discipline both sides of that contract need. Designed for constrained environments.
The Era of Prove It
Federal AI policy has consolidated around high-impact AI, minimum risk-management practices, and acquisition terms that require evidence. Verify current guidance status before relying on any citation; federal AI policy continues to evolve.
Accountability for High-Impact AI
OMB M-25-21 makes agencies responsible for AI governance, including AI operated by contractors: Chief AI Officers, public use-case inventories, and minimum practices for high-impact AI including pre-deployment testing, monitoring, human oversight, and fail-safes.
Governance Through Contract Terms
OMB M-25-22 directs agencies to write contract terms for ongoing monitoring, independent evaluation access, data and IP rights, disclosure of unanticipated vendor AI use, and vendor lock-in prevention. The acquisition lane becomes the control surface when the AI is built, operated, or modified outside the agency's direct technical environment.
Evidence Packages and Suspension Authority
Federal buyers increasingly require tiered evidence packages, verification rights including pre-award testing, and the authority to suspend an AI operation pending investigation, with fail-closed behavior while suspended.
Agencies and Contractors Need the Same Artifact
The asymmetry is structural: the contractor holds the information, the agency holds the accountability. A shared authorization boundary with independently examinable evidence is what closes the gap from both directions.
Accountability without visibility is a trap
Logs record what contractor-operated AI did after the fact. An authorization boundary determines, before release, whether the action was permitted under the applicable policy, authority chain, and oversight condition, and produces the record an Inspector General can examine.
Readiness as competitive position
When evidence requirements appear in solicitations, the gap between contractors who can produce governed, replayable decision records and those who cannot becomes visible. Authorization infrastructure turns a compliance burden into a proposal strength.
The governing control for an effect-bearing AI action is the point at which that action is permitted to release. FERZ evaluates the action against codified rules before that point, issues a verdict of ALLOW, DENY, or ABSTAIN, and records a tamper-evident, replayable authorization artifact. Suspension maps to architecture, not process: while an operation is suspended, execution is blocked, fail-closed, pending recorded and authorized resumption. Distributed authority over governing rules and decision records supports contexts where no single operator may hold unilateral control.
Evidence That Survives an IG Audit
Tamper-evident, replayable
Authorization artifacts designed for independent reconstruction without access to the governed system: policy version, authority chain, proposed action, verdict.
Fail-closed by architecture
Stop before side effects, suspension pending investigation, and blocked execution when governance conditions are not met. These behaviors are architectural commitments, not procedures.
Where the mission runs
Architected for on-premises, air-gapped, and edge environments as well as cloud deployment.
Two Executive Guides, One Boundary
AI Governance for Federal Programs
For program offices, Chief AI Officers, contracting officers, and oversight staff.
Obligations under OMB M-25-21 and M-25-22, illustrative PWS and SOW clause language, evidence requirements scaled by risk tier, verification procedures, and IG audit preparation. Published under CC BY 4.0.
AI Governance for Government Contractors
For contractor executives, capture teams, compliance leads, and delivery organizations.
What is appearing in federal contracts: AI system definitions, the Governed Unit concept, tiered evidence packages, verification rights, and suspension authority, and how to be ready for each. Published under CC BY 4.0.
Talk to FERZ about federal AI authorization
Tell us about your program or contract context. Deployment scope is engagement-dependent.